The heinous crime of Modern Slavery made the headlines again this week. Two brothers have been jailed for six years under the Modern Slavery Act for exploiting Polish workers in Sports Direct’s warehouse in Derbyshire and stealing the majority of their wages. Find more information on this case here.
Although there was no suggestion that Sports Direct were involved in this offence they will not enjoy seeing their name appearing in connection with the case. How confident are you that modern slavery is not present anywhere in your business or your supply chains?
If your global company turnover is over £36 m pa you will need to comply with the Modern Slavery Act. Have you drafted your Modern Slavery Act Transparency Statement yet? The statement must set out what actions the company has taken during the financial year to ensure that slavery is not occurring in their own organisation as well as within its supply chains. That statement must be readily available online, accessible from the company’s homepage.
If a business fails to produce this statement for a particular financial year the Secretary of State may seek an injunction through the High Court requiring the organisation to comply. Failure to comply with the injunction is treated as contempt of a court order, which is punishable by an unlimited fine (in addition to no doubt being obliged to pay the Secretary of State’s legal fees).
Failure to comply together with the potential damage to reputation means that those companies that have not acted should do so as a matter of urgency. A proactive approach, not reactive, is required.
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